You Are Not What Happened to You There
If you or someone you love was trafficked out of a room at the Best Budget Inn on Pulaski Highway in Havre de Grace, or out of any other budget motel along the I-95 corridor through Harford County, this page was written for you. We wrote it because we have seen how the legal system responds to survivors of commercial sexual exploitation when the right law is invoked against the right defendant, and because we have also seen how often survivors are told by well-meaning people that they have no case, that the law does not reach the motel, that they should not name the brand. Most of what you have been told is wrong.
Federal law gives you a private right of action against any business that knowingly benefited from the venture that trafficked you. The law was written precisely for the situation you are sitting with right now. The motel was not a neutral bystander. It rented the room. It took the cash. It set the rate. And in too many cases along the Pulaski Highway and US-40 corridor, motels like this one saw what was happening at the front desk and looked the other way because the rooms kept renting.
This page explains what the law actually says, what Maryland adds on top, who can be held responsible, how long you have to act, what records exist that prove your case, and how we build a claim that can actually collect money — not just a press release. We have included a FAQ section for the questions our clients ask in the first call, and we have spelled out the evidence-preservation clock because waiting even a few weeks can destroy the proof.
A free consultation costs nothing. We work on contingency, meaning no fee unless we win. Past results depend on the facts of each case and do not guarantee future outcomes, and what we describe here is the law and the proof, not a prediction of what your case will return. If you want to talk, the number is 1-888-ATTY-911, and we will pick up.
The Federal Law You Are Invoking: The TVPRA Civil Remedy
The Trafficking Victims Protection Reauthorization Act created a private right of action that allows a trafficking survivor to sue not only the trafficker but also any person or business entity that knowingly benefited financially from a venture it knew, or should have known, was engaged in trafficking.
“An individual who is a victim of a violation of this chapter may bring a civil action against the perpetrator (or whoever knowingly benefits, or attempts or conspires to benefit, financially or by receiving anything of value from participation in a venture which that person knew or should have known has engaged in an act in violation of this chapter) in an appropriate district court of the United States and may recover damages and reasonable attorneys fees.”
— 18 U.S.C. § 1595(a).
This is the central weapon of the case. You do not have to prove the motel itself trafficked you. You have to prove the motel took money from a setup it knew, or should have known, was exploitation. The statute uses the phrase “knew or should have known,” which means the motel’s actual knowledge of trafficking indicators — refusal of housekeeping, repeated cash payments by a third party, a parade of male visitors to a single room, a victim who never appears at the front desk — creates constructive knowledge that legally satisfies this element.
The civil remedy sits on top of the criminal statute, 18 U.S.C. § 1591, which makes sex trafficking a federal crime and requires force, fraud, or coercion. You do not have to prove your case beyond a reasonable doubt. You have to prove it by a preponderance of the evidence — a lower bar.
The damages available under § 1595(a) include compensatory damages, punitive damages, and attorneys’ fees. There is no cap on compensatory damages and no statutory ceiling on punitive damages for trafficking under federal law. Maryland state law additionally provides for compensatory damages, and where conduct is egregious, Maryland permits punitive damages as well.
What Maryland Adds on Top of Federal Law
Maryland has its own trafficking statute and its own civil provisions. The Maryland Code, Criminal Law Title 3, Subtitle 11, criminalizes human trafficking and provides for asset forfeiture against traffickers. The Maryland Code, Criminal Procedure § 11-303, allows trafficking victims to seek restitution in any criminal prosecution of the trafficker.
Maryland’s general personal-injury statute of limitations, Md. Code, Cts. & Jud. Proc. § 5-101, gives a survivor three years from the date the cause of action accrues to file suit in state court. Federal law gives ten years from the date the cause of action arose, or ten years after the survivor reaches age 18 if the survivor was a minor at the time. If you were trafficked as a minor in Maryland, the federal 10-year window does not begin to run until your 18th birthday, which means you can file a federal civil case until age 28.
“No action may be maintained under subsection (a) unless it is commenced not later than the later of—(1) 10 years after the cause of action arose; or (2) 10 years after the victim reaches 18 years of age, if the victim was a minor at the time of the alleged offense.”
— 18 U.S.C. § 1595(c).
If your trafficking occurred between 2013 and 2016 in Havre de Grace, the three-year Maryland state limitation has long since expired. The federal ten-year window is closing or has closed depending on the exact dates. If you were a minor at the time, the federal window from your 18th birthday is still alive. If you were an adult, every month that passes tightens what is left. This is not a case where waiting helps you.
Maryland recognizes a common-law civil action for intentional infliction of emotional distress, and a survivor can plead that claim alongside a federal trafficking claim. Maryland also has a negligence per se framework where violation of a safety statute can be used as evidence of negligence. The Maryland Human Trafficking Task Force, housed within the Governor’s Office of Crime Prevention and Policy, publishes guidance and training resources that can help a fact-finder understand what the industry knew and when.
Maryland follows the doctrine of strict contributory negligence in personal-injury cases. That sounds harsh, but for trafficking survivors it rarely applies. Maryland courts have recognized that a person who is being trafficked is, by definition, not exercising the kind of free choice that would make their conduct comparable to the defendant’s. We address this on a case-by-case basis, but in our experience Maryland juries do not blame trafficking survivors for being victimized, and the contributory-negligence doctrine is a paper barrier more than a practical one in this kind of case.
Evidence That Proves Your Case — And Why the Clock on That Evidence Is Already Ticking
Survivors who call us in the first weeks after escaping a trafficking situation give us the best chance of recovering the evidence that proves the case. Survivors who call us after the case has been cold for months give us less evidence, but the federal statute of limitations still gives us time to litigate. The evidence clock and the legal clock are not the same clock. You have years to sue. You have weeks to months to preserve the proof.
The motel holds the records that decide the case. None of these records are kept indefinitely. A preservation letter sent in week one can mean the difference between a case built on documents and a case built on memory.
Surveillance video. Hotel and motel CCTV systems routinely record over themselves on a rolling loop, commonly 30 to 90 days depending on the system. Many properties overwrite within days. Once the tape is gone, it is gone. Federal Rule of Civil Procedure 37(e) permits a court to impose sanctions, including an adverse-inference instruction telling the jury to assume the missing video was unfavorable to the motel, if the motel lost the video after being put on notice. We send the preservation letter the same week we are retained.
Key-card access logs. Electronic key-card systems record every time a door is opened. These logs show how many times the door to the trafficking room was opened, which is direct evidence of the volume of commercial sex acts occurring in the room. Retention is governed by the property-management system vendor and the property’s own policy; commonly 30 days to one year.
Guest folios and reservation records. The folio shows who paid, how they paid, what room they booked, whether they were a loyalty-program member, and how long they stayed. Cash-only payment is the signature of a trafficking room. Sequential cash payments under a name that does not match the registered guest are the second signature. These records are preserved per the property’s own retention schedule, often one to three years.
Housekeeping and maintenance logs. When a guest refuses housekeeping for the entire stay, the housekeeping log records the refusal. When maintenance is called for a lockout or to replace a key, the maintenance log records it. These logs corroborate the refusal-of-housekeeping red flag and the volume-of-visitors indicator. Retention is commonly six months to one year.
Police call-for-service records. The local police department’s Computer-Aided Dispatch records for the property’s address are public records in Maryland under the Maryland Public Information Act. These records show how many times officers were called to the Best Budget Inn on Pulaski Highway for what kinds of incidents. A history of calls for disorderly conduct, domestic disturbances, or suspicious-person reports at the property is direct evidence that the operator had constructive notice of problems. We obtain these records promptly through a public-information request.
Internal incident reports. If a guest, an employee, or a neighbor ever complained about the trafficking to motel management, the resulting internal report is a critical document. These reports are routinely destroyed in the normal course of business and require a preservation demand.
Employee training records. If the chain’s anti-trafficking training was required but never delivered, that gap is itself evidence of negligence. Employee personnel files are retained per the employer’s policy and per IRS record-retention rules, but they can be hard to obtain without litigation.
The preservation letter we send goes to the operator, the franchisor if any, the property-management company, the local police department, and any third-party vendor that stores the property’s records. It identifies each category of record by name and demands that it be preserved. Once that letter is on file, the motel destroys those records at its peril.
What Your Case Is Worth
The value of a trafficking case against a hospitality operator depends on four inputs: the severity and duration of the trafficking, the strength of the evidence of the motel’s knowing participation, the defendants’ ability to pay, and the jury pool where the case is tried.
Economic damages in a trafficking case include past and future medical and psychological care costs, lost wages and lost earning capacity, the cost of substance-abuse treatment where applicable, and the cost of housing and relocation when the survivor needs to escape the trafficking orbit. These are calculated by a forensic economist using the survivor’s actual work history, the documented medical and treatment records, and the cost-of-care projections from the treating providers. Lifetime costs for the psychiatric care of severe PTSD, major depressive disorder, and substance-use disorders associated with trafficking routinely run into the high six figures to seven figures over a survivor’s expected lifespan.
Non-economic damages include pain and suffering, emotional distress, loss of enjoyment of life, loss of dignity, and the lasting psychological harm of being bought and sold as a commodity. There is no fixed dollar figure for these damages; they are what a jury decides after hearing the survivor’s story and seeing the motel operator’s defense. Federal courts in trafficking cases have returned verdicts and settlements in the millions to tens of millions of dollars; the range is wide and the cases with strong documentary evidence of the operator’s knowing participation have produced the highest results.
Punitive damages are intended to punish the motel for conduct it undertook with knowledge that it was facilitating trafficking, or with conscious disregard of obvious red flags. Maryland permits punitive damages where the defendant’s conduct shows actual malice or its functional equivalent. Federal punitive damages under § 1595 have been substantial in cases where the operator’s conduct crossed from negligence into willful blindness.
Attorneys’ fees are recoverable under § 1595(a), meaning the motel pays our fees in addition to the damages if we win.
A realistic range for a strong trafficking case against a motel operator in Maryland with good documentary evidence is from the low six figures at the low end to several million dollars at the high end, with the very strongest cases — those with powerful surveillance evidence, employee testimony, or a pattern of prior incidents that the operator ignored — reaching into seven figures or higher. We will give you a candid range in your consultation once we have seen the evidence, because the range without the evidence is guesswork.
How We Build Your Case: A Walk Through the First Ninety Days
The first three months of a trafficking case are where the work happens that makes the case either strong or weak. We have built a process that is calibrated for the realities of this kind of litigation, and we walk through it openly so you know what to expect.
Days 1 to 7. We send the preservation letter to every defendant and every third-party record holder. We lock down the motel, the franchisor, the property-management company, the police department, the card-key vendor, the property-management-system vendor, and any third-party booking platform that routed the victim to the property. We send a separate letter to each, identifying each category of record by name. We do this the same week you retain us, not after a month of intake calls. We also send a HIPAA-compliant records request to every treating provider so that the medical record of the trafficking and the aftermath is preserved.
Days 7 to 30. We pull the Secretary of State corporate filings for every entity that may be a defendant. We pull the recorded deed for the property. We pull the franchise agreement if there is one, and we identify the franchisor. We obtain the police call-for-service records for the property under the Maryland Public Information Act. We identify the witnesses: the front-desk staff, the housekeeping staff, the regulars at the motel, the neighbors, the local police officers who responded. We do not contact witnesses yet — we identify them.
Days 30 to 60. We retain a forensic economist to calculate the economic damages. We retain a forensic psychologist or psychiatrist to evaluate the survivor and produce a report that documents the PTSD, the depression, the substance-use disorder if any, and the long-term care needs. We retain a former law-enforcement human-trafficking investigator as a consulting expert. We pull the state’s records of any prior trafficking investigations or prosecutions involving the same motel or the same chain.
Days 60 to 90. We draft and file the complaint. We name every defendant we have identified, and we plead the federal trafficking claim, the Maryland state-law claims, the negligence per se claim under the Maryland anti-trafficking statutes, the negligent-security claim, and the intentional infliction of emotional distress claim. We file in the U.S. District Court for the District of Maryland, Northern Division, because the federal question gives us that venue and the federal attorneys’ fee provision makes the federal forum economically rational.
From filing forward, the case is a fight. We are ready to fight it.
What Happens to the Children
If you were trafficked as a minor, Maryland law and federal law treat you differently. Maryland’s mandatory-reporting law, Md. Code, Family Law § 5-704, requires certain professionals to report suspected child abuse and exploitation. The Maryland Department of Human Services operates a hotline for reports of child trafficking and exploitation. Federal law, 18 U.S.C. § 1591, criminalizes the trafficking of children with no requirement to prove force, fraud, or coercion — the involvement of a minor in commercial sex is itself trafficking.
The civil case we file for a survivor trafficked as a minor is the same kind of case we file for an adult survivor, with the difference that the federal statute of limitations does not begin to run until the survivor’s 18th birthday, and the damages calculation includes the harm done to a child whose developmental trajectory was hijacked by the trafficking. Maryland’s child-protection framework adds an additional layer of available records and a separate set of remedies that we pursue alongside the federal civil case.
If you are reading this and you are the parent of a child who was trafficked at a Maryland motel, we need to talk. The proof we need to gather is different from the proof in an adult case, the damages model is different, and the trauma of a parent learning what happened to their child at a place that was supposed to be safe is its own injury for which the law provides compensation.
Meet the People Who Will Work Your Case
Ralph Manginello has spent 27 years in courtrooms, including federal court. He was born in New York in 1971, moved to Texas at age 5, and was raised in the Memorial area of Houston. He attended the University of Texas at Austin, where he studied journalism and public relations, and then South Texas College of Law Houston, where he earned his J.D. in 1998. He was admitted to the Texas Bar on November 6, 1998. Before he was a lawyer, he was a journalist, and the habits of a journalist — verify everything, write what you can prove, never let the story get ahead of the evidence — are the habits he brings to every case. He is a member of the State Bar of Texas, the Houston Bar Association, the Harris County Criminal Lawyers Association, the Texas Trial Lawyers Association, the National Association of Criminal Defense Lawyers, the Pro Bono College of the State Bar of Texas, and the Trial Lawyers Achievement Association. He has been the lead counsel in significant commercial-litigation matters, including a $10 million-plus hazing case currently active in Harris County. You can learn more about Ralph at his attorney page.
Lupe Peña is a former insurance-defense attorney. He is fluent in Spanish and conducts full client consultations in Spanish without an interpreter. He earned his J.D. from South Texas College of Law Houston in May 2012 and was admitted to the Texas Bar on December 6, 2012. Before law school he earned a B.B.A. in international business from Saint Mary’s University in San Antonio, and he worked in finance before turning to the law. His background in insurance defense is the reason he is on your side: he sat in the rooms where adjusters and their software decided how to deny, delay, and devalue claims exactly like yours. He knows the playbook from the inside. He is a third-generation Texan with family roots to the King Ranch, born, raised, and living in Sugar Land, Texas. He is admitted to the U.S. District Court for the Southern District of Texas, and he has no disciplinary history. You can learn more about Lupe at his attorney page.
Hablamos Español.
We work these cases together. Ralph brings the courtroom experience and the long view. Lupe brings the inside-the-defense perspective and the bilingual client relationship. When you call, one of us picks up.
Frequently Asked Questions
How long do I have to file a trafficking lawsuit against a Maryland motel?
Under federal law, you have 10 years from the date the cause of action arose, or 10 years after your 18th birthday if you were trafficked as a minor. Under Maryland state law, the general personal-injury statute of limitations is three years from the date the cause of action accrues, Md. Code, Cts. & Jud. Proc. § 5-101. The federal 10-year window is generally the longer and more favorable clock, and it is the clock that controls in a case filed in federal court under § 1595. If you were trafficked as a minor in the 2013 to 2016 window at the Best Budget Inn in Havre de Grace, your federal window runs until your 28th birthday.
Do I have to prove the motel knew about the trafficking to win?
No. You have to prove the motel knew, or should have known, under the “knew or should have known” standard in § 1595. Constructive knowledge is established through the recognized red flags of trafficking — repeated cash payments, refusal of housekeeping, high-volume foot traffic to a single room, a guest who never appears at the front desk, sex-related paraphernalia in the room, and prior police calls. If those indicators were present and the motel ignored them, the law treats the motel as having known.
What if I do not remember everything?
Trafficking survivors frequently have fragmented or incomplete memories. The brain’s response to ongoing trauma impairs memory consolidation, particularly for sequence and timeline. Memory fragmentation is well documented in the clinical literature and is routinely explained to juries by expert witnesses. Your case does not depend on you remembering every detail. The motel holds the records — key-card logs, folios, housekeeping logs, surveillance video, police calls — that fill in the gaps.
What if I signed a release when I left the motel?
If you signed a release in exchange for a small cash payment from the motel or its insurer, the release may or may not be enforceable depending on what it said and when you signed it. Releases signed before you had a lawyer are frequently set aside for a variety of reasons, including lack of consideration, fraud or misrepresentation in the inducement, and failure to disclose the federal statutory right of action. Bring the release to your consultation and we will review it. Do not assume it ends your case.
Can I sue both the motel and the brand on the sign?
Yes. The motel operator and the franchisor are different legal entities, and a well-pleaded complaint names both. The franchisor’s potential liability turns on its level of operational control and its receipt of revenue from the trafficking rooms. Federal appellate courts have split on this question, and the pleading matters. We will pull the franchise agreement and the corporate registrations before deciding who to name.
Will I have to testify in court?
Possibly. Many trafficking cases resolve before trial, either through a motion practice or a settlement. If your case proceeds to trial, you will likely need to testify about what happened to you. We prepare you for that testimony in detail, and we bring in expert witnesses — forensic psychologists, former law-enforcement investigators — who carry part of the evidentiary burden so that the case does not stand or fall on your testimony alone. We also have tools to protect you from harassment in cross-examination, including motions in limine and sequestration orders.
What if the trafficker threatens me if I sue?
If you are being threatened, that is a federal crime — 18 U.S.C. § 1513 (retaliation against a witness) — and a state crime. Tell us immediately. We work with victim advocates, the FBI, and Homeland Security Investigations to protect survivors who come forward. The Maryland Network Against Domestic Violence and the Maryland Human Trafficking Task Force can also help. Your safety comes first; the case comes second. If you need shelter, we will help you find it before we file anything.
What if I was using drugs or alcohol while being trafficked?
Maryland follows strict contributory negligence, but trafficking survivors are not, as a rule, held to have contributed to their own victimization. Substance use is often a consequence of trafficking, not a cause of it, and expert testimony routinely explains this dynamic to juries. Your substance use does not bar your case.
What does it cost to hire your firm?
Nothing up front. We work on contingency. We advance the case costs. You pay nothing if we do not recover for you. Our standard contingency is 33.33% before trial, 40% through trial. The federal statute, 18 U.S.C. § 1595(a), allows us to recover our attorneys’ fees from the defendants in addition to your damages if we win in federal court.
How long does a case like this take?
The honest answer is: it depends. A federal trafficking case against a single motel operator typically takes 12 to 24 months from filing to resolution if it settles, and 24 to 48 months if it goes through trial. We do not promise a fast result because a fast result that is wrong is worse than a slow result that is right. We do promise to move the case as fast as the facts and the court allow, and we keep you informed at every step.
Will the case be public?
Federal court filings are public records. Your name will be in the pleadings. You may receive inquiries from other survivors, from the press, or from advocacy organizations. We prepare you for that. If you have privacy concerns, we discuss them with you at the outset and we take protective steps where the law allows, including sealing of certain sensitive documents and protective orders limiting the use of your medical and treatment records. We do not promise to make the case invisible, because we cannot. We do promise to help you manage the visibility.
What is the difference between suing the motel in state court versus federal court?
Federal court gives us access to the § 1595 private right of action and its attorneys’ fee provision, which shifts the cost of litigation to the defendant. State court gives us access to Maryland common-law claims, including negligent security and intentional infliction of emotional distress, which may carry their own damage theories and remedies. In most cases, we file in federal court with a pendant state-law claim so that we have both. The choice is fact-specific and we will explain it in your consultation.
We are ready when you are. 1-888-ATTY-911. Free consultation. No fee unless we win. Hablamos Español.